Disproportional nightmare scenario

There are two weeks left to comment on the Cornwall Local Plan.

Its important Cornwall Council knows what people think, although the way they design documents and response forms isn’t always inviting.

I sent my response this weekend, the gist of which is that the draft local plan is a nightmare scenario, rather than a plan for sustainable development.

One issue is the fiction that the development proposals and housing allocations are ‘proportional’.

4 per cent of Cornwall’s population live in Truro/Kenwyn. In 2013 Cornwall Council proposed 2,200 new dwellings in Truro/Kenwyn, ie 5 per cent of the development planned by 2030.

The latest draft plan proposes increased housing numbers, allocating a whopping 16 per cent of this proposed increase to Truro. No rhyme or reason, just the fictional claim the proposed allocations are ‘proportional’ alongside the equally bogus claim that the distribution of numbers in the plan supports Cornwall’s dispersed settlement pattern.

The LEP

Cornwall Local Economic Partnership has recently published its Strategic Economic Plan and Local Growth Fund bid.

The ‘Truro Western Corridor’ scheme (which forms part of the Local Growth Fund bid) includes some improvements which are needed on a very congested route near Cornwall’s largest hospital.

However, the LEP webpage with these two documents says: ‘Please note the final version of the SEP and LGF are currently in the design stage but the text and content will not change.’ 

That’s more than unfortunate as the Local Growth Fund Bid – which is after all a bid to spend public money – contains some bogus numbers in relation to Truro. (And in any case surely even after printing they could easily correct genuine errors online.)

Cornwall Council is currently consulting on the draft local plan including ‘The provision of around 3000 dwellings up to 2030′ in Truro/Kenwyn. This is an increase compared to the earlier proposal of 2200 dwellings.

But the LEP Local Growth Fund Bid instead claims: ‘Truro Local Plan proposals Houses: 4,500′.

Apparently traffic isn’t the only thing that might speed up if the funding is secured; the LEP claims the proposal ‘Accelerates the delivery of 1,127 houses and unlocks private sector investment to deliver the infrastructure to support a further 2,677 new homes to the north of the A390.’

Reality check anyone? In relation to Cornwall Council’s current consultation on increasing housing numbers from 2200 to 3000, just under 3200 dwellings already have planning permission in Truro/Kenwyn including 1615 north of the A390.

Maybe the wrong numbers are typos, but if so I hope the LEP got their financial figures right.

I heard back from someone at Cornwall Council about this, who said 4500 was a mistake, but suggested the other figures are correct, which clearly they can’t be.

‘and you caring enough to pay for it’

This is a quick post to note that the NPPF enables ‘locations of deprivation which may benefit from planned remedial action’ to be identified in local plans.

In Cornwall, the draft strategic policies of the local plan allow for this possibility, but PP6 does not; despite the fact that the economic data shows that – statistically – there are three deprived areas in Truro/Kenwyn, and in February 2013 there were 777 children assessed as living in poverty.

In the context of Cornwall, Truro has a reputation for being able to pay our own way; but we do need strategic and targeted community investment.

‘And thinking how little you cared for the cost, and you caring enough to pay for it’ Ezra Pound

‘bring out number weight and measure’

The housing SHMNA on which Cornwall Council has based its latest draft housing proposal refers to two independent economic assessments which forecast 30,800 or 39,700 additional jobs in Cornwall by 2031; this is alongside the fact that the data used shows that 17,400 jobs have been lost in Cornwall since 2007. However, without explanation the draft local plan now out for consultation has slashed jobs projections from 50,000 to 25,000 compared to the 2013 consultation draft – this would mean net growth of 7,600 jobs in Cornwall by 2030 compared to jobs in 2007. In contrast, the LEP draft economic strategy projects 47,500 new jobs, but this number is not based on any independent economic assessment – it is based on their assumption that jobs will grow in tandem with housing based on Cornwall Council’s consultation proposal.

Retail and employment space projections in the draft local plan are based on studies completed alongside the now abolished RSS projections of population growth. Cornwall Council decided recently to update its retail study, but the latest draft local plan carries forward outdated office assumptions. Look around you; if you are in Truro or at Threemilestone industrial park you will see empty office buildings.

The NPPF says planning must be ‘realistic’. In a million years, I don’t think Cornwall Council is going to be able to justify the economic and jobs ‘data’ in the 2014 draft local plan; nor to explain how their jobs projection can be sensibly linked to the SHMNA – if they choose to rely on it – nor to the draft LEP strategy, which makes the mistake of using housing numbers as a proxy for jobs and basing itself on the false prospectus which, in the absence of economic intervention, is Cornwall’s only draft local plan.

‘Bring out number weight and measure in a year of dearth’ William Blake, Proverbs of Hell.

‘enough! or too much!’

The draft local plan which is out for consultation includes housing and economic data for the community network area and within that, separately, for Truro/Kenwyn and the rest of the network area.

In so far as there has been public debate about the draft local plan in the media, they have followed the lead of Cornwall Council and focused on whether housing numbers might go up as well as down. The Truro/Kenwyn plan agreed in responding to last year’s consultation on the draft local plan not to ask for changes to the 2200 homes proposed for Truro/Kenwyn.

Over 3000 planning permissions are already granted, including some homes completed since 2010 (the start of the plan); if 20% or more of the uncompleted planning permissions were not built, at least 2200 will be provided by 2030. The draft local plan identifies jobs growth of 2150 in Truro by 2030. The housing number of 2200 is broadly consistent with the LEP draft economic strategy which envisages housing and jobs numbers growing in tandem up to 2031 (whether or not that’s sensible – see next post).

However, the draft local plan consultation now proposes a higher housing figure of 3000 in Truro/Kenwyn, which I think it would be reasonable to reduce. The draft strategic policy 2 refers to ‘providing homes and jobs in a proportional manner’, which is a reasonable approach in terms of sustainability. If it were decided for example to grow the number of households in Cornwall by 20% (which is what is proposed in the consultation document), then – as the households in Truro/Kenwyn comprise 4% of Cornish households – it would be proportional to allocate 4% of new dwellings to Truro/Kenwyn – ie a total of 1900 by 2030.

In relation to affordable housing the proportions in this draft local plan are also reasonable (40% in Truro/Kenwyn and 50% on former public sector land). However, the daft policy 11 wholly undermines this by showing numerous ways in which developers might use ‘viability’ to argue for a lower proportion of affordable housing; but would never be asked to consider renegotiating other aspects of the development to ensure delivery of affordable homes. I understand the policy context, which is likely to change before 2030, and first and foremost I think the local plan should support the community’s reasonable expectations.

The higher total for Cornwall of 47,500 in the 2014 consultation is based on a 2013 Strategic Housing Market Needs Assessment. The SHMNA is an assessment of the housing market which emerged from a clear recognition that the housing market was failing to meet housing need; the policy approach to the housing market has now changed, and the Government revised and published new guidelines in March 2014 on housing need and economic development assessments, confirms: ‘Local planning authorities may consider departing from the methodology, but they should explain why their particular local circumstances have led them to adopt a different approach where this is the case.’ So a Cornwall-led approach to housing development is possible, if Cornwall Council were only willing to step up to the responsibility. It would take a bit more time but it might transform the draft local plan from the timid and confused jumble of contradictions that it is into a locally led plan for genuinely sustainable development.

People may or may not be good with numbers, but they intuitively understand the community’s need for housing and have opinions as to whether the housing market projections – in the words of William Blake – are ‘Enough! or Too Much!’. Most people would prefer a more straightforward assessment of the housing needs in Cornwall, and recognise that developers’ greed and the demands of the housing market on Cornwall are something else again, and environmentally not sustainable.

‘a green thing that stands in the way’

The NPPF planning principle to ‘encourage the effective use of land by reusing land that has been previously developed (brownfield land)’ and the opportunity ‘to consider the case for setting a locally appropriate target for the use of brownfield land’ both appear to have been overlooked or ignored by Cornwall Council planners, but would make all the difference in Truro where 50 per cent of new homes in 2001-11 were provided on brownfield sites and several others are likely to come forward. Bizarrely in the context of Cornwall, the draft local plan places a stronger emphasis on reusing previously developed land in rural areas than in towns, despite the fact that the NPPF stresses reusing buildings and brownfield sites – including for housing – to support the vitality and viability of town centres.

I think Cornwall’s local plan needs a specified target for the proportion of housing and other development which will be accommodated on brownfield land. This would be a positive addition to draft strategic policy 2 (spatial strategy), which already includes some other reasonable sustainability principles, but which are not then followed through fully in other draft policies.

In draft strategic ‘policy 23 – natural environment’ the track changes in the ‘mitigation’ section shows that the frank recognition that some developments cause ‘loss’ to the natural environment and landscape character has been deleted and replaced with the words ‘adverse impact’. Unfortunately mitigation only partly works; if you introduce light pollution or remove trees, and plant new trees in ‘mitigation’ – as with the planning permission at Tolgarrick in Truro – you will get 30-40 years of light pollution and open views of a new housing estate, followed by an effective screen of mature trees in front of 30-40 year old housing.

It was William Blake (1757-1827) who may have first recognised that ‘The tree which moves some to tears of joy is in the eyes of others only a green thing that stands in the way’.

‘a wide wall of sandbags’

The draft local plan strategic policy numbered 26 is largely reasonable. But as some planning permissions (and other developers’ applications) have come forward in advance of any site allocations it isn’t clear that flood risk and coastal change have been or are being adequately considered.

To be parochial about this, in the context of Truro, South West Water have confirmed that they are willing to increase sewerage capacity to accommodate development. The capacity works which are in hand in Truro centre are long overdue. To accommodate building out the Langarth planning permission for 1500 homes west of Threemilestone an additional main sewer would be needed.

However, during a councillors’ visit to the sewerage treatment works at Newham it was confirmed (1) the new main sewer would be connected to the existing sewerage treatment works; (2) the increased effluent would increase flood risk, but it was then said that this risk would be a matter for the Environment Agency. Unfortunately the ‘duty to co-operate’ in planning infrastructure sometimes seems to result in a purposeful fragmentation of responsibility.

It may be important to ensure, as draft policy 26 says, that planning: ‘does not create avoidable future liability for maintenance for public bodies and communities’; but strategically it is more important to make sewerage arrangements which don’t increase flood risk in an area which we know – and the Environment Agency confirms – is already prone to flooding.

In the poem in which Ezra Pound referred to ‘a wide wall of sandbags’ he said ‘there is nothing to do but keep on’. But (Langarth outline permission aside) we still have time to make a responsible choice here; to put flood risk and coastal change at the heart and forefront of Cornwall’s local plan and all the remaining specific site and planning decisions in Truro/Kenwyn and elsewhere. To do that we need to listen to ‘sound science’; and to recognise that preventing flood risk is more important than increasing profits or dodging corporate liability. And draft strategic policy 26 sensibly includes the possibility of relocating development where necessary to minimise flood risk.